Functional comparability under TNMM: broadcasters excluded, software distributors included, and no separate interest on receivables after working capi...
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Extra Duty Deposit in related-party provisional assessment proceedings is refundable once final valuation shows no further duty payable, because the deposit is not customs duty and does not survive as a deficiency payment. On delayed refund, the Section 27A interest principle applies mutatis mutandis: interest runs from expiry of three months after the refund entitlement arises until actual payment, even if the amount had earlier been credited to the Consumer Welfare Fund on unjust enrichment grounds. The denial of interest was set aside and refund interest was held payable.
Extra Duty Deposit in related-party provisional assessment proceedings is refundable once final valuation shows no further duty payable, because the deposit is not customs duty and does not survive as a deficiency payment. On delayed refund, the Section 27A interest principle applies mutatis mutandis: interest runs from expiry of three months after the refund entitlement arises until actual payment, even if the amount had earlier been credited to the Consumer Welfare Fund on unjust enrichment grounds. The denial of interest was set aside and refund interest was held payable.
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